Privacy Policy

At OneEast Capital, the privacy of your personal information is important to us. Our Privacy Policy is designed to provide you with general information about what and how we collect, store, use, disclose, and otherwise handle your personal information. We will handle your personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Act) and this Privacy Policy.

This Policy relates to OneEast Capital and its Australian related bodies corporate (together “OneEast”, “we”, “us” and “our”).

OneEast reviews its policies, statements, and procedures to keep up to date with changes in the law, technology, and market practices. As a result, we may update and change our Privacy Policy from time to time. We encourage you to occasionally review this Policy so that you are aware of our most up-to-date practices, including any recent changes or updates.

If you require any further information concerning privacy and the ways in which we handle your personal information, please contact us using the contact details set out at the end of this Policy.

1. What personal information do we collect and hold?

We may ask for a range of personal information about you because of the nature of our products and services and the laws and regulations that govern us. We will collect personal information that is reasonably necessary to allow us to provide you with our products and services, send you news and insights, comply with laws and regulations, and assist and support you with your needs. Depending on the requested products or services, the nature of your relationship with OneEast (e.g., if you are acting on behalf of a corporation or institutional client), and your interactions with employees of OneEast, we may collect the following types of personal information (including but not limited to):

Types of Personal Information

Example

General information

Name, Date of birth, Gender, Signature, Occupation

Contact details

Mobile or telephone number, Residential and/or postal address, Email address

Government issued identifications

Driver licence details, vehicle licence details, passport details, Medicare number, Tax File Number (TFN)

Financial Information

Banking details (BSB and Account Number), Tax, income, assets and liabilities information, Employment details (including the organisation you represent), Insurance policies, Securityholder Reference Number (SRN), Holder Identification Number (HIN)

Sensitive Information

Health information, Political affiliations

Digital Information

Internet protocol (IP) Address, Cookies

Sometimes we need to collect sensitive information about you in order to be able to provide you with a product or service. In the unlikely event that we need to collect sensitive information from you, we will only do so with your consent, unless an exemption under the Privacy Act 1988 (Cth) applies.

If you do not consent to your personal information being used as described in this Privacy Policy or if you do not provide the personal information requested, it may prevent us from arranging for some or all of the products or services you require, or the product or service which we do provide might not fully meet your needs.

2. How do we collect your personal information?

We normally obtain personal information directly from you; for example, we collect personal information through onboarding forms and other documents or through correspondence with you in person, over the phone, or electronically. We collect personal information from you during our onboarding process and throughout the course of providing you with products and services. When we collect personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your personal information, who we may disclose it to, and outline how you can access it, seek correction of it, or make a complaint.

We may also collect personal information from you in the course of your use of our website if you input any personal information. In addition, we may also collect cookies from your computer, which enables us to tell when you use the website and also to help customise and improve your website experience (see Internet Privacy below). From time to time, we may also ask for additional personal information (for example, through market research, surveys, or special offers) to enable us to improve our service or consider the wider needs of our clients or potential clients.

There may be occasions when we need to source personal information about you from a third party. For example, we may collect personal information from third parties such as product providers, brokers, agents, accountants, and other intermediaries, family members, or government agencies to provide you with the services that you request from us. Where we collect personal information from a third party, we will take reasonable steps to let you know that we have your personal information unless it is obvious from the circumstances that you know or would expect us to have the personal information.

In the event that we receive unsolicited personal information about you that is not relevant to our purposes for collecting personal information, we will destroy the information.

If you have a general enquiry, you can choose to submit these anonymously or use a pseudonym. However, we may not always be able to interact with you this way because we are governed by strict regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:

  • It is impracticable; or

  • We are required or authorised by or under law, such as the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or a court/tribunal order to deal with you personally.

The regulations governing the services we provide require your identity to be made known to and verified by us. Without that personal information, we cannot provide our services. You don’t have the option of providing ‘anonymous’ personal information or using a pseudonym.

3. How we use your personal information

The purpose of collecting personal information is to provide you with the products and services you’ve asked for, to understand and meet your needs, and to provide you with a wide range of financial and other products and services.

The personal information collected will be used and disclosed (non-exhaustive list):

  • To give you information about a product or service and/or consider whether you are eligible for a product or service;

  • To process your application for a product or service and/or administer the product or service we provide you;

  • To manage our relationship and/or services provided to you and exercise our rights described in application/service agreement terms and conditions between you and us;

  • To allow us to run our business and perform administrative and operational tasks such as training staff, developing and marketing products and services, risk management, systems development and testing (including our websites and other online channels), undertaking planning, research and statistical analysis;

  • To identify you and prevent or investigate any fraud or crime, or any suspected fraud or crime;

  • If it will prevent or lessen a serious and imminent threat to somebody’s life or health;

  • As required by laws, regulations, court orders, or codes binding us, for example, to verify your identity as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);

  • For purposes related to the above; and

  • For any purpose for which you have provided express (verbal or written) or implied consent.

Disclosure to third parties

To make sure we can meet your specific needs, and for the purposes described above, we sometimes need to share your personal information with our related bodies corporate and others, including but not limited to:

  • Those involved in providing, managing, or administering your product or service, for example, superannuation funds, insurance companies, other lead managers, responsible entities, investment managers, platform providers, share registries, and banking or financial institutions.

  • External third-party service providers who help us operate our business and who have been contracted to provide OneEast with administrative, audit, brokerage, and settlement, banking, financial, insurance, research, tax, marketing, legal or other services.

  • Those who assist us in providing products and services to you and in managing your personal information.

  • Government or regulatory bodies (including ASIC and the Australian Taxation Office) as required or authorised by law or regulations.

  • Any other individuals, bodies, or agencies that you have granted express permission to, would reasonably expect, or you have been told, that information of that kind is usually passed to.

We will take reasonable steps to ensure third parties have the necessary controls and practices to comply with the relevant privacy legislation and to only use personal information for the prescribed purposes.

Disclosure of personal information overseas

We may disclose your personal information to recipients (e.g., individuals or entities) outside of Australia for the purposes listed above. We may disclose to overseas recipients within the following countries (including but not limited to):

  • United States

  • United Kingdom

  • Singapore

Where personal information is disclosed overseas to a third-party recipient, we take reasonable steps to ensure:

  • That the recipient does not breach the Privacy Act and the Australian Privacy Principles,

  • That the recipient is subject to an information privacy scheme similar to the Privacy Act; or

  • That you have consented to the disclosure.

4. How do we take care of your personal information?

We take appropriate steps to protect the personal information we hold about you from interference, misuse, loss, unauthorised access, modification, or disclosure. Specifically, our security measures include, but are not limited to:

  • Educating our staff about their obligations with regards to your personal information and taking appropriate rectification measures and disciplinary action where there is a breach.

  • Restricting access to your personal information on a ‘need-to-know’ basis.

  • Only giving access to personal information to a person who is authorised to be able to receive that information.

  • Transfer of significant or sensitive personal information via an approved, secure channel.

  • Electronic security systems, such as firewalls and data encryption.

  • Secure storage and encryption of personal information across multiple physical and electronic repositories.

  • Access to our offices is restricted to our personnel and third-party service providers with appropriate authorisation.

If we no longer need your personal information, we will take reasonable steps to destroy it securely, or permanently de-identify it, in accordance with the requirements of the Act. Where required by law, we will archive your personal information.

Internet privacy

We take reasonable steps to ensure your personal information is secure when using our website and online services, and that it is treated in accordance with the Act and the Australian Privacy Principles.

When you use our website, we may collect information about your location or activity, including your IP address, which may be identifiable to you. We use cookies and other web analytics to collect this information. A cookie is a small text file placed on your computer, mobile, or another device by websites that you visit. We use cookies to help improve your experience when visiting our websites, for example, to identify and provide the most relevant pages and interactive tools.

You can manage your cookie settings through your web browser, or via your settings on mobile devices. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, this may impact the website’s functionality. For more information about cookies, please see www.allaboutcookies.org. The information collected by cookies will be used for internal purposes only. We will not share this information with any other party.

Links to external websites

Our website may, from time to time, contain links to websites of third parties. OneEast is not responsible for the privacy practices or the content of any such websites. We encourage you to read and understand the privacy policies of relevant third parties before providing any information to them.

5. Access to your personal information

Subject to the exceptions outlined in the Privacy Act, you may access any of your personal information that we hold. We will generally provide access to your personal information if practicable (which may be by allowing you to inspect your personal information or by providing you with a copy) within a reasonable period (usually 30 days) of receiving your written request. You will not be charged for making an access request, but you may be charged for the reasonable cost of providing you with access to this information.

You can request access to your personal information or a correction of it, by contacting us using the contact details set out at the end of this Policy.

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, complete, and up to date. Please inform us as soon as possible if you notice that any of your personal information held by us is not correct or up to date. We will take reasonable steps to correct any personal information once we are made aware of any errors or omissions.

There may be situations where we refuse you access to the personal information we hold about you. For example, we may refuse access when:

  • The request is frivolous or vexatious; or

  • Providing access would have an unreasonable impact on the privacy of others; or

  • The information relates to existing or anticipated legal proceedings; or

  • The information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations; or

  • Providing access would be unlawful; or

  • Denying access is required or authorised by or under law; or

  • Providing access would be likely to prejudice certain operations by or on behalf of an enforcement body; or

  • An enforcement body performing a lawful security function requests access to personal information.

If we refuse access to or correction of your personal information, we will write to you explaining the reasons for this. You have a right to request a review of our decision.

6. Making a privacy complaint

If you wish to complain about any breach or potential breach of this privacy policy or the Australian Privacy Principles, you should contact us in writing using the contact details set out at the end of this Policy.

We will aim to resolve your complaint as quickly as possible, usually within 30 days. If you’re not satisfied with our response, or the time taken to resolve the complaint, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the OAIC by:

7. Contact Us

You can contact us about this Policy or about your personal information by:

  • Writing OneEast Capital, Level 3, 162 Collins Street, Melbourne VIC 3000

  • Email info@oneeastcapital.com.au